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Petitioners were not entitled to avail themselves of the
150-day filing period. Accordingly, respondent’s motion to
dismiss will be granted.3
An appropriate order of
dismissal will be entered.
3Petitioners also make a generalized claim that they were
denied due process during the partnership level proceeding. The
partnership level proceeding preceded and was completed prior to
the notices of deficiency upon which the petition in the instant
case was based. Our jurisdiction to consider any of petitioners’
arguments must be based upon a timely petition. As we have held,
we lack jurisdiction because the petition in this case was not
filed within the statutory time limit.
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Last modified: May 25, 2011